Memorandum Findings of Fact and Opinion
This proceeding was initiated to test the correctness of the respondent's determination of a deficiency in income tax for the fiscal year ending November 30, 1939, in the amount of $509.30, a personal holding company surtax in the amount of $3,480.86, and a penalty of $870.22 for failure to file a personal holding company surtax return. Two questions are raised. The first issue is whether or not petitioner was a personal holding...
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